The European Accessibility Act (EAA) introduced a harmonised framework across the EU to enhance access to key products and services for persons with disabilities. Cyprus transposed the EAA into national law through the Accessibility of Products and Services Law of 2024 (the "Law"), which came into force on 28 June 2025. This development has important consequences for services providers, including, financial service providers operating in Cyprus.
Legal Background
The Law applies to both products and services offered within the EU, aiming to remove barriers for persons with disabilities. It defines "persons with disabilities" as those with long-term physical, mental, intellectual or sensory impairments that may hinder their participation in society on an equal basis with others.
Applicability to Financial Services Providers
From 28 June 2025 onwards the Law applies to services, inter alia, consumer banking services, which include services that are covered under MiFID II Directive (2014/65/EU), such as the reception and transmission of orders, execution of orders, portfolio management, and investment advice.
Key Obligations
- Accessible Information: Documents that contain information such as financial documents, contracts, statements, policies, onboarding forms, must be perceivable through visual, auditory, and alternative formats and be compatible with assistive technologies.
- Accessible Digital Services: Websites and mobile applications must be fully usable by persons with disabilities. This includes being of adequate font size, contrast, spacing, and provide support for alternative text and assistive technologies.
- Accessible Support Services: Customer support must offer accessible communication modes and inform users about the compatibility with assistive technologies.
- User-Friendly Security Features: Authentication and identification procedures must be operable and understandable. Complexity should not exceed B2 level of the Council of Europe's Common European Framework of Reference for Languages.
Exemptions
- Microenterprises (fewer than 10 employees and turnover or balance sheet under €2 million).
- Obligations may be waived if they impose disproportionate burden or fundamentally change the service provided.
Transitional Period
- Existing contracts and/or services (offered before 28 June 2025) to continue until 28 June 2030.
- New services introduced after 28 June 2025 must comply immediately.
Penalties
- Administrative Fines: up to €10,000 initially; up to €20,000 for repeated offences.
- Criminal penalties: up to 2 years' imprisonment or a €20,000 fine; up to 3 years' imprisonment or a €30,000 for repeated offences.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
